Paul Davidoff was happy to be one of a number of leading practitioners to be quoted in an article written by Citywealth’s Karen Jones who had reached out to experts to explore how The Cayman Islands continues to evolve as a global hub for trust and estate planning, digital asset innovation, and family office migration.
Topics included:
- The Future of Cayman Trusts in 2025
- The Enduring Role of STAR Trusts in Wealth Planning
- Cayman Foundation Companies: A Perfect Fit for DAOs
- Enhancements in Trusts & Family Office Growth
- Cayman’s Strengthened Position as a Premier Jurisdiction for Digital Assets
- A Hub for Digital Asset Innovation and Institutional Investment
- Cayman’s Trust Structures: Tailored Solutions for High-Net-Worth Families
- Relocation Trends of UHNWs to the Cayman Islands and Their Impact on Philanthropy
- Reside Cayman: Navigating Immigration and Residency in a Growing Cosmopolitan Utopia
- A Destination for Wealth Management and Tech
- Key Tax and Trust Considerations for UK Expats and Investors
On this last topic, this is what Paul had to say: “My Cayman-based clients typically fall into two categories – UK expat lawyers or retired lawyers who moved to Cayman to work, often with partners or spouses from the UK or elsewhere. Some have done very well, especially those who have been in Cayman for 30+ years and UK expat business owners or retirees living in Cayman. Most of my Cayman clients (who haven’t been UK residents for many years) are happy with the changes to the non-dom rules. However, clients who have been living in the UK for some time and expected to remain there for at least 14 years without detrimental tax treatment are concerned.”
Paul goes on to express his views on Inheritance, Income, and Capital Gains Relief: “Some clients may want to return to the UK to retire or temporarily move for their children’s education. If they’ve been non-UK residents for 10 consecutive tax years, they’ll receive beneficial income tax and capital gains tax treatment for the first four years back in the UK. While this regime is simpler than the current remittance-based taxation, its limitation to four years is seen as a drawback. However, it’s still an improvement over the current system. Returning to the UK for up to nine years won’t trigger inheritance tax on foreign assets. Some clients may be able to avoid inheritance tax sooner if they were not UK domiciled on 30th October 2024 (Budget Day) and became non-UK residents by 6th April 2025, or if they were UK residents for 10 to 19 of the 20 years before leaving the UK. For some, it could take only 3 years. As a transitional rule, non-doms who leave the UK by 6th April 2025 after completing up to 14 years of UK residence will be outside the scope of inheritance tax on non-UK assets, as long as they stay non-UK residents. If they return to the UK, the rules will change.”
Paul then provides some commentary on the new rules:
“Some clients may want to return to the UK to retire or temporarily move for their children’s education. If they’ve been non-UK residents for 10 consecutive tax years, they’ll receive beneficial income tax and capital gains tax treatment for the first four years back in the UK. While this regime is simpler than the current remittance-based taxation, its limitation to four years is seen as a drawback. However, it’s still an improvement over the current system. Returning to the UK for up to nine years won’t trigger inheritance tax on foreign assets. Some clients may be able to avoid inheritance tax sooner if they were not UK domiciled on 30th October 2024 (Budget Day) and became non-UK residents by 6th April 2025, or if they were UK residents for 10 to 19 of the 20 years before leaving the UK. For some, it could take only 3 years. As a transitional rule, non-doms who leave the UK by 6th April 2025 after completing up to 14 years of UK residence will be outside the scope of inheritance tax on non-UK assets, as long as they stay non-UK residents. If they return to the UK, the rules, will change.”
Karen Jones concludes the article with the confirmation that The Cayman Islands is indeed a future-ready hub for global wealth, innovation, and lifestyle.
